Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Assessee trust formed on 02.09.2014 but granted registration u/s 12AA from AY 2016-17 onwards. For AY 2015-16, exemption u/s 11 denied due to lack of registration. Relying on precedents, it was held that where registration is granted during pendency of appeal, benefit of Section 11 cannot be denied for the year under consideration. CIT(A)'s observations regarding applicability of Section 13 to loans/advances given to spouses of Principal/Administrator expunged, as provisions of Section 13(3)(cc) do not extend to manager/spouse of trust. CIT(A)'s enhancement of income by crediting Amalgamation Fund and Building Fund set aside, as assessee applied more than 85% of receipts for charitable objects, satisfying conditions for Section 11 exemption. CIT(A) exceeded enhancement powers by directing assessment on new source of income.
Assessee trust formed on 02.09.2014 but granted registration u/s 12AA from AY 2016-17 onwards. For AY 2015-16, exemption u/s 11 denied due to lack of registration. Relying on precedents, it was held that where registration is granted during pendency of appeal, benefit of Section 11 cannot be denied for the year under consideration. CIT(A)'s observations regarding applicability of Section 13 to loans/advances given to spouses of Principal/Administrator expunged, as provisions of Section 13(3)(cc) do not extend to manager/spouse of trust. CIT(A)'s enhancement of income by crediting Amalgamation Fund and Building Fund set aside, as assessee applied more than 85% of receipts for charitable objects, satisfying conditions for Section 11 exemption. CIT(A) exceeded enhancement powers by directing assessment on new source of income.
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